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Nicole Corrine Beauvais, Ch. 7, BK14-40365 (June 12, 2014)

The court denied the debtor’s uncontested motion to avoid a non-possessory, non-purchase-money security interest in the vehicle she uses to commute to work. Following the holding of In re Cardwell, Case No. BK13-40623 (Sept. 12, 2013), the court ruled that simply using a vehicle for commuting is not sufficient to define it as a tool of the trade under federal law, and federal law determines the availability of lien avoidance.